Virginia Graeme Baker Act

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Virginia Graeme Baker Act

• Waterpark Industry

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Overview

• We support the goals of the Act
• Single, blockable drains should comply with the
  Act.
• Water attractions are not traditional pools
• Waterparks currently employ multiple layers of
  anti-entrapment features
• Applying ANSI/ASME A112.19.8 to water attractions
  is not appropriate. It creates technical
  operational issues, which may result safety
  hazards.
• Applying ANSI/IAF-9, ASTM, and other technical
  standards is a viable solution

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Waterpark Industry

• Outdoor and indoor waterparks
• more than 1,000 waterparks in North America
• Over 85 million in attendance annually
• growth average 3-5 each year
• Communities served
• Private companies large and small
• Municipalities
• Hotel Resorts
• Community Centers
• Suppliers Manufacturers
• Body of professionals dedicated to waterpark
  safety standard writing (ASTM and ANSI)
• Employee base ranges from 20 to 5,000 persons per
  park
• Many parks will be open December 20th going into
  the busiest part of the year.

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What is a typical swimming pool?
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Virginia Graeme Baker Act Definition of
Swimming Pool or Spa

• From Section 1403
• Swimming pool spa. The term "swimming pool" or
  "spa" means any outdoor or indoor structure
  intended for swimming or recreational bathing,
  including in-ground and above-ground structures,
  and includes hot tubs, spas, portable spas, and
  non-portable wading pools."

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Typical Swimming Pools
Community Pools
Competitive Pools
Residential Pools
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Typical Swimming Pool Spa Features

• Flat water
• Smaller systems and drains

• Few walking surfaces
• Few interactive features

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What is a waterpark attraction?
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ANSI/IAF-9 Defines Aquatic Recreation Facilities
as
Class D, other pool Any pool operated for
medical treatment, therapy, exercise, lap
swimming, recreational play, and other special
purposes, including, but not limited to, wave or
surf action pools, activity pools, splasher
pools, kiddie pools, and play areas. Class D-1,
wave action pools Wave action pools include any
pool designed to simulate breaking or cyclic
waves for purposes of general play or
surfing Class D-2, activity pools Activity
pools are those pools designed for casual water
play ranging from simple splashing activity to
the use of attractions placed in the pool for
recreation Class D-3, catch pools Catch pools
are bodies of water located at the termination of
a manufactured waterslide attraction provided for
the purpose of terminating the slide action and
providing a means for exit to a deck or walkway
area. Class D-4, leisure rivers Manufactured
streams of near-constant depth in which the water
is moved by pumps or other means of propulsion to
provide a river-like flow that transports bathers
over a defined path that may include water
features and play devices. Class D-5, vortex
pools Circular pools equipped with a method of
transporting water in the pool for the purpose of
propelling riders at speeds dictated by the
velocity of the moving stream. Class D-6,
interactive play attractions Only water
treatment and filtration for these attractions
are within the scope of this standard. A
manufactured water play device or a combination
of water-based play devices in which water flow
volumes, pressures, or patterns are intended to
be varied by the bather without negatively
influencing the hydraulic conditions of other
connected devices. Class D-6 attractions may
incorporate devices or activities such as slides,
climbing and crawling structures, visual effects,
user-actuated mechanical devices and other
elements of bather-driven and bather-controlled
play. Class D-6 attractions do not incorporate
captured or standing water greater than 12 inches
deep as part of the bather activity area. Class
D-7, amusement park attractions Attractions or
rides traditionally found in amusement parks that
are designed to permit bather contact with water.
Class D-8, natural bodies of water Those
natural or man-made aquatic play areas normally
regarded as oceans, lakes, ponds, streams,
quarries, or bodies of water that the local
jurisdiction has designated as Natural Bodies of
Water. The design or construction of these
facilities is not included in the scope of
ANSI/NSPI standards.
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Wave Pools
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Activity Pools
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Waterslides
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Leisure and Action Rivers
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Interactive Aquatic Play Structures
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Simulated Surf Rides
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What makes waterpark attractions different from a
typical swimming pool?
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Waterparks are complex
Waterpark 30 drains, various sizes
Typical swimming pool 3 drains, lt18x23
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Comparison on Dimensions Use
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Unique Features of Waterpark Attractions

• Large bodies of water
• Moving, shallow water
• Walking surfaces
• Interactive features
• Use of tubes, rafts, mats
• Partially submerged skimmers
• Lifeguards

• Several anti-entrapment features are utilized
• Large unblockable drains
• Gravity drains
• Multiple drains
• Water velocities at drains less than 1.5 ft/sec

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Circulation grates are larger than 18x23
(unblockable) and multiple drains are installed
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Drain grates are large and designed to achieve
water velocity of less than 1.5 ft/second
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Gravity Drainage System
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Multiple main drains with drain cover centers at
least 3 feet apart
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Dual Sumps
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Drain Grates larger than 18x23(unblockable)
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Large, unblockable drains
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Challenges
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Challenge Drain grates, larger than 18x23 are
prevalent in waterparks. Compliant grates in
sizes larger than 18x23 are not
available. Year-round operations will be in
violation of the law without alternatives on
December 20th

• Today
• Water attractions employ various layers of
  anti-entrapment features
• Multiple drains
• Velocities less than 1.5 ft/sec
• Drains are unblockable

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Challenge Commercially available, compliant
drain grates are domed or raised. Domed drain
grates on walking surfaces pose a tripping
hazard. Play areas need flush mounted grates.
Entry/exit to zero depth attraction

• Today
• Flush drain covers comply with ANSI/IAF-9
• Multiple drains spaced appropriately
• Drains larger than 18x23
• Gravity drains
• Flows less than 1.5 feet per second

ASME compliant grates would protrude creating
trip and fall hazards
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• Challenge
• Compliant grates have a different design from the
  existing grate.
• Changing the grate could increase the flow
  velocity to exceed the system design or could
  starve the pump.
• Could also result in non-compliance with the ASME
  standard regarding flow velocity.

Drain cover has specific sized opening to achieve
flow velocity

• Today
• Drains compliant with ANSI/IAF-9 to achieve
  anti-entrapment
• Multiple drains spaced appropriately
• Drains larger than 18x23
• Gravity drains
• Flows less than 1.5 feet per second

ASME compliant grate could have smaller openings
resulting in change in flow velocity
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ChallengeEven if the cover meets the
requirements of the standard, there is a
reluctance by licensed engineers to certify
existing drain grates.
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Summary

• 1 - The ANSI/ASME standard was not written with
  waterpark facilities in mind.
• 2 - Our industry supports laws that enforce
  anti-entrapment compliance. Consideration of the
  unique features of water attractions is needed.
• 3 - Technical requirements for anti-entrapment
  should be addressed in other ANSI and ASTM
  standards specific to waterpark attractions.
• 4 Rushing to implement ANSI/ASME 112.19.8 for
  water attractions may lead to additional
  unanticipated safety hazards.

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Proposed Solutions
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• ASME
• Addresses design and testing of drain grates and
  sumps
• Defines anti-entrapment based on water flow
  velocity and drain dimensions
• Refers to ANSI/IAF-9 for other anti-entrapment
  solutions
• Test methods limited to 18x18 grates
• Written by commercial pool suppliers,
  manufacturers, consultants, etc.

• IAF-9
• Addresses design and construction of Aquatic
  Recreation Facilities (waterparks)
• Defines anti-entrapment features required of the
  entire system, regardless of drain size.
• Written by waterpark operators, designers, safety
  consultants, and suppliers.

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Each document presents only a part of the overall
system

• A specific standard is needed to address the
  unique requirements of drains in water
  attractions
• ASTM F24.70 has a task group organized to
  incorporate the existing standards and address
  the specific requirements of water attractions.
• This standard would address the specific
  challenges identified in this presentation.

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Conclusion

• Although we believe the definition of "swimming
  pool" and "spa" in Section 1403(6) of the
  Virginia Graeme Baker Pool and Spa Safety Act
  does not include waterpark attractions, the
  waterpark industry wants to do everything
  possible to meet appropriate safety standards.
• The waterpark industry currently employs safe
  anti-entrapment features and practices.
• Waterparks are unique in design and
  configuration, with specific safety performance
  requirements.
• Therefore, we would like clarification that the
  Act and ANSI/ASME A112.19.8 does not apply to
  water attractions so we may work on an ASTM
  standard WK 21536 to incorporate existing
  standards and address the specific challenges
  shown above. 
• We welcome future inclusion in the Act when
  appropriate technical standards are developed.